UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
March 19, 2009
IN RE KLA-TENCOR CORP. SHAREHOLDER DERIVATIVE LITIGATION
The opinion of the court was delivered by: The Honorable James Ware United States District Judge
This Document Relates To: ALL ACTIONS.
STIPULATION AND [PROPOSED] ORDER FURTHER EXTENDING TIME FOR FILING PLAINTIFF'S MOTION TO COMPEL
WHEREAS, by Stipulation and Order dated January 16, 2009, this Court approved KLA-Tencor Corp. ("KLA") and lead plaintiff's schedule for lead plaintiff's requested document production from KLA;
WHEREAS, this schedule provided that on or before March 2, 2009, lead plaintiff would file a motion to compel, if any, regarding KLA's response and objections to lead plaintiff's request for production of documents;
WHEREAS, on March 11, 2009, the Court approved the parties' March 2, 2009 Stipulation and [Proposed] Order Extending Time for the Filing of Plaintiff's Motion to Compel until March 16, 2009 in light of the parties' ongoing settlement discussions;
WHEREAS, the parties are continuing to discuss a possible settlement of this action, and certain parties have scheduled an additional mediation session with the Honorable Layn Phillips (Ret.) for March 31, 2009;
WHEREAS, lead plaintiff and KLA believe that the parties' best interests are served by briefly extending the date by which lead plaintiff may file a motion to compel, if any, to April 6, 2009.
NOW, therefore, the parties agree and stipulate, subject to Court approval, as follows:
Without deciding any issues pertaining to the appropriateness and proper scope of discovery at this time, if any, all of which issues are expressly reserved, KLA and lead plaintiff agree that any motion to compel regarding the request for documents served pursuant to the Court's January 16, 2009 Order shall be filed no later than April 6, 2009.
DATED: March 16, 2009
I, Shawn A. Williams, am the ECF User whose ID and password are being used to file this Stipulation and [Proposed] Order Further Extending Time for Filing Plaintiff's Motion to Compel. In compliance with General Order 45, X.B., I hereby attest that Thomas R. Green has concurred in this filing.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
CERTIFICATE OF SERVICE
I hereby certify that on March 16, 2009, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e-mail addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF participants indicated on the attached Manual Notice List.
I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on March 16, 2009.
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